Update on Independent Audit Thresholds for the 2025 Fiscal Year
The financial thresholds used to determine which companies must undergo independent audit have been updated, effective for fiscal periods from 1 January 2025. Under Presidential Decision No. 9774, published in the Official Gazette on 1 May 2025 (No. 32887), the criteria, particularly for companies categorized under “List II”[1], have been substantially increased. This change will alter the audit landscape for many Turkish businesses, especially small and medium-sized enterprises, and warrants a careful review of recent financial data.
What Has Changed
The regulation revises the asset and revenue thresholds that trigger an independent audit requirement, while employee headcount thresholds remain unchanged. The new thresholds apply prospectively to the 2025 fiscal year.
Updated thresholds for List II companies
Total assets of at least TRY 120 million
Annual net sales revenue of at least TRY 150 million
An average of at least 100 employees
Updated thresholds for companies that are neither publicly held nor listed under List II
Total assets of at least TRY 300 million
Annual net sales revenue of at least TRY 600 million
An average of at least 150 employees
Relative to the prior framework, the financial criteria have nearly doubled, while the employee thresholds are unchanged.
The decision applies to fiscal periods starting on or after 1 January 2025. A company becomes subject to independent audit in 2025 if, in both 2023 and 2024, it exceeds at least two (2) of the three (3) criteria (total assets, annual net sales revenue, or number of employees) under the relevant category.
Practical Implications and Next Steps
By raising the financial thresholds, the regulation narrows the scope of companies required to undergo independent audit, easing compliance for many organizations, particularly for SMEs. That said, companies operating near the new thresholds should conduct a careful review of their 2023 and 2024 figures to assess audit obligations for 2025 and adjust governance and reporting processes accordingly.
For tailored guidance on how these changes could affect your company’s governance or reporting obligations, please contact your CMS partner or local CMS expert: Dr Döne Yalçın.
[1] List II includes companies in which at least 25% of the share capital is held by public‑interest professional organizations, unions, associations, foundations or cooperatives; companies publishing nationwide daily newspapers; companies (excluding call centers) subject to the regulatory and supervisory framework of the Electronic Signature Law, Electronic Communications Law, Postal Services Law, and TCC Article 1525 (i.e., companies regulated by the Information and Communication Technologies Authority); energy companies operating under the licenses or regulatory oversight of the Energy Market Regulatory Authority (EPDK); companies transferred to the management and supervision of the Savings Deposit Insurance Fund (TMSF); and economic enterprises in which municipalities hold 50% or more of the share capital. For the further details, please refer to: Official Gazette – Presidential Decision No. 6434.
